United States Nuclear Power
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Russell Turner Interview
Guest Name: Russell L. Turner
Company: Nuclear Management Company
Plant Name: Point Beach Nuclear Plant, Units 1 and 2
Position or Title: ISI Engineering Coordinator
ASME Code of Record: Section XI - 1998 Edition 2000 Addenda
OM Code - 1995 Edition 1996 Addenda
ASME Section XI/OM Inspection Interval: Fourth Interval
E-Mail Address: firstname.lastname@example.org
Phone Number: 920-755-6212
Question: How many personnel do you have in your ISI/IST organization and how are the responsibilities distributed between the ISI/NDE, Risk Informed, Pump and valve, Containment, System Pressure Test, Snubber, Repair/Replacement Programs, etc.?
Turner: Since the first interview, things have changed a bit. There are now two NDE technicians (down from three) and a Level III NDE supervisor, an ISI coordinator for ISI, RI-ISI, R/R Activities, and pressure testing , IST coordinator, containment engineer for IWE/IWL/Appendix J, a scheduler who also handles all scheduling of NDE, ISI, and administers state requirements (he is also a certified NDE examiner), and a FAC engineer.
Question: How much of the NDE is actually performed by your organization, if any, in lieu of utilizing outside vender support, and if so, what savings have you recognized by using your in-house personnel?
Turner: The majority of NDE between outages is performed by in house NDE, which is approximately 40%. During an outage, contractors help. We have PDI qualified personnel on staff. Having the NDE personnel on site has eliminated the need for contractors between outages except for RT Personnel.
Question: What changes have you made in your organizational structure or reporting functions that you have found to be beneficial?
Turner: There has been some reorganization due to the formation of the Nuclear Management Company, but it has not resulted in any drastic changes within our group. The IST Program was moved under a different supervisor, but his physical location, responsibilities, and interfaces did not change.
Question: What issues proved to be very difficult, costly, or troublesome to resolve, and what would you recommend to avoid those issues in the future?
Turner: Point Beach just went through an ISI Program update to the 1998 Edition/2000 Addenda of Section XI. We requested to use this edition/addenda so when the other NMC sites updated their ISI Programs in the next two years, we would not be behind them. The actual update was time consuming with a steep learning curve. The structure of the ISI Program was completely changed to make future updates less painful. As for recommendations to others, don't wait until the last minute to write the new Program. It took us a year to find all the extra requirements that had been imposed by the NRC and others, get them integrated or changed to meet new requirements, and to figure out what other changes were required for the plant. ISI procedures proved to be particularly difficult due to the large number of them and their almost total rewrite. An even larger number of procedures throughout the plant referenced the old 1986 Code. It was not possible to change the reference to the 98A00 Code because of the exceptions in 10CFR50.55a, the RI-ISI implementation, and several relief requests, so we had procedures changed to say, as referenced in the ISI Program. That seemed to satisfy everyone and prevents the plant from having to update many procedures unnecessarily every time a requirement changes.
Question: What code cases or relief requests have you implemented that have proven to be very helpful and cost effective?
Turner: We have implemented N-460, N498-1, N-513, N-522, N-523-1, N-532-1, N-533-1, N-566-1, N-616, and N-624. N-616 has proved to be very useful. Previously, we had quite a few other Code Cases implemented, but the new Code eliminated the need for many of them.
Question: Has your organization implemented a risk informed ISI or IST program, and if so, what Code Cases or methodology did you incorporate and what benefits and savings have you realized? What was the scope of the program and the approximate costs to develop the program? Were there any unexpected problems encountered while developing the program? Did you receive any requests for additional information from the NRC and has your program been approved?
Turner: The RI-ISI program has been developed using the EPRI methodology. It was implemented July 1, 2002 along with the new ISI Program. Point Beach, along with the rest of the NMC, chose to do both class 1 and 2 systems. It appears that radiation dose has been cut in half and it appears the costs for an outage are down about half. The cost was about $230k for the analysis plus about 200 hours of my time researching plant records, scheduling examinations, and adding a new system. The only unexpected problem was the addition of the Auxiliary Feedwater system. Section XI changed the exemption criteria for this system, and at Point Beach, it is quite large, with over 600 new line items.
Question: What form of training has proven to be the most successful for your group; in-house instruction, vendor instruction, organizational instruction (EPRI, NSSS, etc.), conferences, technical meetings, online learning, etc.? What ISI/NDE training seminars are you considering for attendance in the near future?
Turner: We had Roger Reedy come in to train on Section III. This was helpful for repair/replacement. There are also the ASME conferences.
Question: What new NDE techniques, technology, or special NDE situations have you encountered recently and was it successful?
Turner: We have been using PDI NDE techniques and procedures. They seem to be working well and have cut down examination time.
Question: Has your organization implemented the requirements for ASME Section XI, Appendix VIII, of the 1995 Edition with the 1996 Addenda. Did you utilize the recommended EPRI format for relief requests, and if so which ones? What is the approval status of your relief requests and what problems or successes have you encountered in implementing Appendix VIII?
Turner: We are implementing the supplements of Appendix VIII as mandated by 10CFR 50.55a, the latest rule. We have not requested any additional relief's for Appendix VIII at this time, but we are looking at a couple.
Question: What do you find to be the most difficult part of your job?
Turner: Finding the time to get everything done. The ISI Program at Point Beach is mostly brand new, so the learning curve was initially quite steep. This has shown us where improvements need to be made. Along with outage scheduling demands and all the other little items constantly being assigned, time always seems to be at a premium. With a better ISI software program that is slowly being filled with information, updated procedures that give more guidance than before, better drawings and information, and more attention from management, things have improved tremendously over the last three years.
Question: What do you find to be the most rewarding part of your job?
Turner: Knowing that the ISI Program is being implemented in the correct fashion with no NRC or QA problem areas. Much of the time we all need to be self-satisfied, as there is little acknowledgement of our efforts.
Question: What have you found to be the most humorous experience on the job?
Turner: There are so many…hmm…. One would be when I gave a class on ISI requirements. We were about 30 minutes into the class (dull, glazed over look from about 3/4 of the people) when I asked if anyone had any questions. After a few seconds, one person asked me, What is CFR, ISI, and NDE? We started the class over. Funny now, but quite painful at the time.
Question: Have you had any difficulties or questions regarding the code classification of system components or establishing the code classification boundaries? If so, what difficulties or questions did you encounter and how did you resolve the issues? What technical positions did you take?
Turner: In the beginning, the two units were handled separately, with two people putting together the code boundaries. There were some differences in several areas. Only when laying the documents side by side and doing extensive comparisons did the differences begin to show. This has resulted in several small areas being added to the program when they should have been there from the beginning (no violations were found). There is a scheduled update of the ISI Basis Document sometime next year, so the boundaries should be clearly spelled out. There are no technical positions taken over any piping except what would be considered industry standards.
Question: Have you had any difficulties or questions applying the Section XI Repair/Replacement Rules to components, spare parts, etc.. If so, what difficulties or questions did you encounter and how did you resolve the issues? What technical positions did you take?
Turner: The are many new rules for R/R Activities in the 98A00 Code. Some helped tremendously, as they clearly spell out many areas that everyone knew from tribal knowledge earlier. It also eliminated some of the R/R Activity rules for snubbers and relief valves. We have not taken any technical positions that are outside the normal from what is found within the industry.
Question: Does your organization plan to implement a Section XI edition and/or addenda that is later than currently required in 10 CFR 50, and if so, what benefits do you anticipate?
Turner: We asked and received permission to use the 1998 Edition with 2000 Addenda when we updated the ISI Program. The biggest benefit was using a Code edition with many of the Code Cases we would have asked to use via relief already being included. There are also many areas clarified, particularly in the R/R Activity area.
Question: Do your NDE procedures include a methodology for calculating the examination coverage for limited examinations, and if so, how is this calculation performed and what considerations are included?
Turner: Our methodology for determining coverage varies from outage to outage and person to person. There is no procedure, but it is becoming more standardized. With six plants, different NDE groups, and changing personnel, this may become a problem. As long as everyone agrees that the bottom line is have we done everything reasonable to get the most coverage, then it does not matter how the calculation is performed. This causes problems for those of us who have to write relief's where different methodologies are being used.
Question: Does your plant share any calibration blocks on a regular basis with other plants outside of your organization, and if so, what types of blocks do you share and who do you share them with?
Turner: We share our blocks with other plants. We also borrow blocks. These have been mostly vessel blocks, but with the new NDE training requirements, PDI blocks have recently been shared on a regular basis.
Question: As outages become shorter and shorter, how are you able to handle your ISI work load during the outage? Are you supplementing your staff with additional temporary personnel or are some tasks getting deferred?
Turner: We are looking at performing ISI examinations on a round the clock basis during an outage, which means extra staffing. The extra personnel come from other NMC plants or from contractors. We also perform the FAC examinations and any other NDE that is required by other groups, such as new construction or maintenance.
Question: Has your current or prior organization ever lost accountability of their ISI/IST program due to inadequate record keeping, non-documented plant modifications, etc.? What activities were lacking that led to the situation? What efforts were required to reconcile, verify, and/or validate the database to get the program back to a state of confidence? What controls were put in place to ensure that such an incident would not occur again?
Turner: The ISI Program was not properly maintained for several years. Starting in 1998, the ISI and other programs were rebuilt, with several people being hired to handle it adequately. The biggest problem appeared to be management buy-in, but that has been resolved. There is an effort ongoing to identify what examinations were performed in the past. These records are available, but not easily accessed. Plant modifications were not always transmitted to the ISI Coordinator so the ISI Program was not continually updated. Summer students were brought in to help and it appears all these areas have been found and accounted for before regulatory problems could arise.
Question: What type of software do you use to track and analyze ISI program commitments and inspection data? Was the software developed by your organization or purchased from a vender? Does it adequately meet your needs? If not, why not?
Turner: We use WinISI for the ISI database. This database has information relating to every component in the ISI Program and contains the commitments for why an examination is being performed (if an augmented exam). It handles our RI-ISI information and outage results, and is user customizable. The next update to the program is supposed to have the ability to send database information to data sheets, which would eliminate some transcription errors.